Privacy Policy

Introduction

Thank you for visiting the MYBX trading platform (hereinafter referred to as "MYBX"). By accessing, entering, or using MYBX and its related application programming interfaces (APIs) or mobile applications (collectively referred to as the "Platform"), you agree to the provisions and practices set forth in our Privacy Policy (hereinafter referred to as "this Privacy Policy"). Please be sure to read this Privacy Policy carefully.

 

This Privacy Policy explains how MYBX will use your personal data (as defined below) when you use our digital asset trading platform services through our software, application programming interfaces, technologies, products, and/or features (collectively referred to as the "Services").

 

In the course of providing Services to you, we need to collect and store your personal information to comply with the legal requirements of the jurisdictions where we operate and to improve the quality of our Services. Generally, we will never disclose customers' personal information to any unrelated third parties, except as otherwise specified below.

 

We may update this Privacy Policy at any time and will notify you by posting the revised version on the Platform.

Data We Collect

MYBX collects, processes, and stores personal data obtained through your use of the Services or collected with your consent. Such personal data may include:

 

Virtual identity information: MYBX account/password, MYBX nickname.

Sensitive and biometric personal data: Where permitted by local law or with your consent, MYBX may also collect sensitive personal data, such as biometric information. For example, verifying your identity by comparing facial scan data extracted from your selfie or video with the photo on your government-issued identification document.

Financial information: Bank account information, primary account number (PAN) of payment cards, account assets, transaction history, transaction data, and/or tax identification number.

Transaction information: Information related to transactions you conduct on the Platform, such as the payee's name, your name, transaction amount, and/or timestamp.

Message content: Feedback, emails, text messages, app ratings, comments.

App usage behavior: Browser operation records, click records, search history, installed apps, running apps, crash logs, user-generated content, favorites, mouse movement trajectories, scroll positions, keystrokes, and touch operations.

Device information: Carrier, brand, software version, model name, manufacturer, system language, operating system version, regional settings, device fingerprint, build number, baseband version, country of SIM card, SIM card serial number, battery status, network information, Open Anonymous Device Identifier (OAID), International Mobile Equipment Identity (IMEI), Globally Unique Identifier (GUID), Media Access Control (MAC) address, Android ID, Service Set Identifier (SSID), Advertising ID, and gyroscope/accelerometer data.

Communication records: Survey responses, information provided to our customer service team or user research team.

Audio, electronic, visual, and similar information: Such as call recordings, video recordings.

 

We may collect information you provide during the MYBX registration process (whether the registration process is completed, incomplete, or terminated). When providing Services to residents of specific jurisdictions, we collect, store, and process your personal information in accordance with local data protection laws (such as the General Data Protection Regulation (GDPR) and Data Protection Act).

 

In addition, to comply with applicable anti-money laundering laws and regulations, we may collect the following personal information:

(1) Individual Customers

Email address

Mobile phone number

Legal full name (including former names and names written in local language)

Nationality

Passport number or number of any government-issued identification document

Date of birth (DOB)

Identification documents (such as passport, driver's license, or government-issued identification card)

Residential address

Proof of residence documents

Other personal data or documents required by the compliance team based on their judgment

(2) Corporate Customers

Legal name of the company (including legal name written in local language)

Incorporation information

Legal full names of all beneficial owners, directors, and legal representatives

Addresses (principal place of business and/or other actual business premises)

Proof of legal existence documents

Business description

Shareholding percentage of individual/corporate owners

Contact information of owners, responsible persons, and senior management (if applicable)

Identification documents of the key individual beneficial owners of the institutional customer entity (such as passport, driver's license, or government-issued identification card)

Personal data of the key individual beneficial owners of the institutional customer entity (for specific personal data collected, please refer to the "Individual Customers" section above)

Proof of source of funds

Amount of Bitcoin or other digital assets planned to be deposited

Access, Correction, Deletion, and Other Rights Relating to Your Personal Data

Under applicable law, as described below, you have multiple rights regarding privacy protection and personal data protection. You have the right to request access to, correction of, and deletion of your personal data, and the right to request data portability. In certain cases, you may also object to our processing of your personal data or request that we restrict the processing of your personal data. In addition, after you consent to our processing of your personal data for specific purposes, you may withdraw such consent at any time.

 

If you wish to exercise any of the rights listed below, please contact our Data Protection Officer via email at [e-mail].

 

In certain cases, these rights may be restricted. For example, when applicable laws or anti-money laundering compliance requirements oblige us to process your personal data, your relevant rights may not be fully exercised.

 

Right of access: You have the right to confirm whether your personal data is being processed, to obtain a copy of your personal data, and to obtain specific information related to data processing.

Right of correction: You may request the correction of your inaccurate personal data and the supplementation of your incomplete personal data. You may also modify your personal data in your account at any time.

Right to erasure: In certain cases, you may request the deletion of your personal data.

Right to object: Based on your specific circumstances, you have the right to object to our processing of your personal data. For example, you have the right to object when we process your personal data based on legitimate interests or for direct marketing purposes.

Right to restriction of processing: In specific cases, if there are valid reasons, you have the right to request that we temporarily restrict the processing of your personal data. However, we may continue to process your personal data for the purpose of defending legal claims or in other circumstances permitted by applicable law.

Right to data portability: In certain cases, you may request that we provide you with the personal data you previously provided to us in a structured, commonly used, and machine-readable format; where technically feasible, you may also request that we transmit your personal data directly to another data controller.

Right to withdraw consent: For the processing of personal data that requires your consent, you have the right to withdraw your consent at any time. The withdrawal of consent does not affect the legality of data processing conducted based on your consent before the withdrawal.

 

Exercising the above rights may affect the form and content of the Services we provide to you. In certain cases, exercising these rights may result in our inability to continue providing Services to you, and therefore we may need to terminate the contract signed with you.

 

We may charge a reasonable processing fee for your request to access personal data. If we decide to charge a fee, we will provide you with a written estimate of the fee. Please note that unless you agree to pay the fee, we are not obligated to respond to or process your access request.

Methods of Collecting Personal Data

Most of the personal information we collect is directly provided by you. We collect and process your information in the following circumstances:

 

(a) When you register online, log in, or access MYBX, or use any MYBX Services;

(b) When you voluntarily complete any user survey or provide feedback to us via email or other channels;

(c) When you use or browse our website or client, and information is collected through Cookies (Cookies refer to small amounts of data sent by a website to a browser and stored on the computer's hard drive) in your browser or software;

(d) Other circumstances of collecting information by ourselves as mentioned in this Agreement.

 

We may also obtain your information from public channels or third-party channels (such as our advertising partners and market research partners), for example, to update or supplement other information we have collected about you.

Methods of Using Personal Data

We may use your personal data in the following ways:

(1) Compliance with Laws and Regulations

Most of our Services are subject to laws and regulations that require us to collect, use, and store your personal data in specific ways. For example, MYBX must identify and verify the identity of customers using our Services to comply with cross-jurisdictional anti-money laundering laws. This includes collecting and storing photos of your identification documents. If you fail to provide personal information as required by law, we may have to close your account.

(2) Enforcement of the Terms of This Agreement

We will actively monitor, investigate, prevent, and mitigate any potential prohibited or illegal activities, enforce the agreements we have signed with third parties, and prevent and verify violations of this Agreement. In addition, your use of our Services may require the payment of corresponding fees. We will collect information about your account usage and closely monitor your interaction with our Services. We may use any personal information we have collected about you for the above purposes.

(3) Detection and Prevention of Fraud and/or Financial Loss

We will process your personal information to help detect, prevent, and reduce fraud and abuse of our Services, and to protect the security of your account.

(4) Provision of Services

To provide Services to you, we need to obtain your personal information. When providing identity verification and/or fraud prevention services, third parties (such as identity verification service providers) may also collect your personal information.

(5) Provision of Service Communications

We will send you administrative or account-related information to keep you informed of the latest developments of our Services, notify you of relevant security issues or updates, or provide other transaction-related information. Without such communications, you may not be able to promptly learn about important matters related to your account, which may affect your use of our Services. You cannot opt out of receiving important service communications (such as emails or text messages) sent for legal or security purposes.

(6) Provision of Customer Service

When you contact us to resolve relevant issues, we will obtain your personal information. Without processing your personal information, we will not be able to respond to your request or ensure that you can use our Services without interruption.

(7) Ensuring Network and Information Security

We will process your personal information to enhance security, verify your identity and access rights to our Services, prevent spam or other malicious software and security risks, and comply with applicable security laws and regulations. It is crucial to promptly and accurately understand how you use our Services. Without processing your personal information, we may not be able to ensure the security of the Services.

(8) Research and Development

We will obtain your personal information to better understand how you use and interact with our Services. In addition, we will use this information to customize and improve the content and interface layout of the Services, and to develop new Services. Without processing your personal information, we may not be able to ensure that you can continue to use our Services.

(9) Enhancing Your User Experience

We will obtain your personal information to provide you with a personalized experience and meet your needs. For example, you may allow us to access specific personal information stored by third parties. Without processing your personal information, we may not be able to ensure that you can continue to use some or all of the Services.

(10) Supporting Corporate Acquisitions, Mergers, or Transactions

In the event of a corporate acquisition, merger, or other business transaction, we may obtain your account information and information related to your use of our Services. If you do not want your personal data to be processed for such purposes, you may choose to close your account.

(11) Conducting Marketing Activities

We may send you marketing communications (such as emails or text messages) to inform you of our events or events of our partners, provide targeted marketing services, or send you promotional offers. Our marketing strategies will be based on your advertising and marketing preferences and implemented within the scope permitted by applicable law. If you do not want us to send you marketing information, please contact our Data Protection Officer via email at [e-mail].

(12) Other Purposes with Your Consent

With your consent, we may disclose your personal information for any purpose you approve.

 

Notwithstanding the above provisions, we may also share your personal data with the following individuals or entities in the following circumstances:

 

Affiliated companies: As a regular part of conducting business and providing Services to you, the personal information we collect and process may be transmitted among various companies under MYBX.

Third-party service providers: We may engage other companies or individuals to perform certain functions on our behalf, such as data analysis, marketing support, payment processing, content delivery, and credit risk assessment and management. These third-party service providers may only access the personal information necessary for performing their functions and may not use it for other purposes. In addition, they must process personal information in accordance with our contractual agreements and within the scope permitted by applicable data protection laws.

Law enforcement authorities: In accordance with legal requirements or court orders, we may need to disclose your relevant information or information related to our cooperative relationship with you to relevant regulatory authorities, law enforcement authorities, and/or other competent authorities. We will disclose your information to law enforcement authorities within the scope prescribed by law. In addition, we may need to share your information to enforce or assert our legal rights or to prevent fraud.

Business transfers: As our business continues to develop, we may acquire or sell other businesses or services. In such transactions, user information is usually one of the transferred business assets, but it must still comply with the commitments in the previous privacy notice (unless the user consents otherwise). In addition, if MYBX or most of its assets are acquired by a third party (although such a situation is relatively unlikely), user information will also be part of the transferred assets.

Protecting the Rights and Interests of MYBX and Others: When we believe that disclosing information is helpful for complying with laws or fulfilling regulatory obligations, enforcing or applying our User Agreement and other agreements, or protecting the rights, property, or safety of MYBX, users, or others, we will disclose account information and other personal information. This includes exchanging information with other companies and organizations to prevent fraud and reduce credit risks.

 

MYBX will not provide, sell, rent, share, or trade your personal information to any unrelated third parties, unless we have obtained your prior consent, or the third party has provided Services to you independently or jointly with MYBX (including our affiliated companies), and after the termination of the Services, the third party will be prohibited from accessing such information (including all information it was previously entitled to access). MYBX also does not allow any third party to collect, edit, sell, or disseminate your personal information in any way. If any MYBX user is found to engage in the above activities, MYBX has the right to immediately terminate the service agreement with that user.

 

If you are not a natural person with full capacity for civil rights and civil conduct, you have no right to use this Service. Therefore, MYBX recommends that you do not provide any personal information to us.

Information Storage

The information and materials we collect about you will be stored on the servers of MYBX and/or its affiliated companies. This information and materials may be transmitted to countries, regions, or locations outside the country where MYBX collects the information and materials, and may be accessed, stored, and displayed in regions outside the country of origin of the information. By submitting personal data, you consent to such transmission, storage, and/or processing. For more information about the transfer of personal data outside the European Union and information related to users within the European Union, please refer to the "Supplementary Terms Applicable Only to EU Users" section.

Cross-Border Transmission of Information

To support our global operations, MYBX may transmit your personal information to regions outside the European Economic Area (EEA). Transmission to regions outside the European Economic Area is sometimes referred to as "third-country transfer".

 

We may transmit your personal information to our affiliated companies, third-party partners, and service providers around the world. When we intend to transmit personal information to a third country or international organization outside the European Economic Area, MYBX will take appropriate technical, organizational, and contractual safeguards (including standard contractual clauses) to ensure that such transmission complies with applicable data protection regulations.

 

We will also transmit information in accordance with the relevant decisions of the European Commission to countries and regions outside the European Economic Area that the European Commission has determined to provide an adequate level of protection for personal information. Such decisions are referred to as "adequacy decisions".

Cookies

(1) Installation of Cookies

When you visit the Platform, the Platform uses Google Analytics (Google Stats) through Cookies to record the operation of the Platform and detect the effectiveness of online advertisements. Cookies are small amounts of data sent to your browser and stored on your computer's hard drive. Cookies are only sent to your computer's hard drive when you access the Platform using a computer.

(2) Functions of Cookies

Cookies are often used to record the habits and preferences of visitors when browsing various types of content on the Platform. The information collected by Cookies is anonymous aggregated statistical information that does not include personal data and cannot be used to obtain information from your hard drive, email, or personal data. However, Cookies allow the Platform or service provider's system to identify your web browser and obtain and remember relevant information.

(3) Disabling Cookies

Most browsers are set to accept Cookies by default. You can choose to set your browser to reject Cookies or notify you when Cookies are installed. Please note that if you choose to disable Cookies, you may not be able to launch or use certain functions of the Platform. In addition, if you choose to reject Cookies, you may not be able to log in or use Platform Services or functions that rely on such Cookies. This section applies to any relevant information obtained through Cookies set by MYBX.

Information Security

Your account is protected by security measures. Please keep your account and password information properly. We will ensure that your information is not lost, misused, or tampered with by storing backups on other servers and encrypting user passwords.

 

Despite the above security measures, please note that there are no "absolutely perfect security measures" in information networks. When you use our Platform Services to conduct online transactions, you will inevitably disclose your personal information (such as contact information or mailing address) to the counterparty or other potential counterparties. Please properly protect your personal information and only provide it to others when necessary. If you find that your personal information (especially your account and password) has been